Consultation Document on Listing Eligibility and Conservation
Actions
Notoryctes caurinus (Kakarratul)
You are invited to provide your views, and reasons supporting them, related to:
1)
the eligibility of Notoryctes caurinus (Kakarratul) for inclusion on the EPBC Act threatened
species list; and
2)
the necessary conservation actions for the above species.
Note: The information contained in this conservation advice was primarily sourced from ‘The
Action Plan for Australian Mammals 2012’ (Woinarski et al., 2014). Any substantive additions
obtained during the consultation on the draft will be cited within the advice. Readers may note
that conservation advices resulting from the Action Plan for Australian Mammals show minor
differences in formatting relative to other conservation advices. These are reflective of the desire
to achieve efficiency over preparation of a large number of advices by adopting the approach of
the Action Plan for Australian Mammals in presentation of information and do not reflect any
difference in the evidence used to develop the recommendation.
Evidence provided by experts, stakeholders and the general public are welcome. Responses
can be provided by any interested person.
Anyone may nominate a native species, ecological community or threatening process for listing
under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) or for a
transfer of an item already on the list to a new listing category. The Threatened Species
Scientific Committee (the Committee) undertakes the assessment of species to determine
eligibility for inclusion in the list of threatened species and provides its recommendation to the
Australian Government Minister for the Environment.
Responses are to be provided in writing either by email to:
species.consultation@environment.gov.au
or by mail to:
The Director
Marine and Freshwater Species Conservation Section
Wildlife, Heritage and Marine Division
Department of the Environment
PO Box 787
Canberra ACT 2601
Responses are required to be submitted by 8 May 2015.
Contents of this information package
General background information about listing threatened species
Information about this consultation process
Draft information about the Kakarratul and its eligibility for listing
Conservation actions for the species
References cited
Consultation questions
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General background information about listing threatened species
The Australian Government helps protect species at risk of extinction by listing them as
threatened under Part 13 of the EPBC Act. Once listed under the EPBC Act, the species
becomes a Matter of National Environmental Significance (MNES) and must be protected from
significant impacts through the assessment and approval provisions of the EPBC Act. More
information about threatened species is available on the department’s website at:
http://www.environment.gov.au/biodiversity/threatened/index.html.
Public nominations to list threatened species under the EPBC Act are received annually by the
department. In order to determine if a species is eligible for listing as threatened under the
EPBC Act, the Threatened Species Scientific Committee (the Committee) undertakes a rigorous
scientific assessment of its status to determine if the species is eligible for listing against a set of
criteria. These criteria are available on the Department’s website at:
http://www.environment.gov.au/biodiversity/threatened/pubs/guidelines-species.pdf.
As part of the assessment process, the Committee consults with the public and stakeholders to
obtain specific details about the species, as well as advice on what conservation actions might
be appropriate. Information provided through the consultation process is considered by the
Committee in its assessment. The Committee provides its advice on the assessment (together
with comments received) to the Minister regarding the eligibility of the species for listing under a
particular category and what conservation actions might be appropriate. The Minister decides to
add, or not to add, the species to the list of threatened species under the EPBC Act. More
detailed information about the listing process is at:
http://www.environment.gov.au/biodiversity/threatened/nominations.html.
To promote the recovery of listed threatened species and ecological communities, conservation
advices and where required, recovery plans are made or adopted in accordance with Part 13 of
the EPBC Act. Conservation advices provide guidance at the time of listing on known threats
and priority recovery actions that can be undertaken at a local and regional level. Recovery
plans describe key threats and identify specific recovery actions that can be undertaken to
enable recovery activities to occur within a planned and logical national framework. Information
about recovery plans is available on the department’s website at:
http://www.environment.gov.au/biodiversity/threatened/recovery.html.
Information about this consultation process
Responses to this consultation can be provided electronically or in hard copy to the contact
addresses provided on Page 1. All responses received will be provided in full to the Committee
and then to the Australian Government Minister for the Environment.
In providing comments, please provide references to published data where possible. Should the
Committee use the information you provide in formulating its advice, the information will be
attributed to you and referenced as a ‘personal communication’ unless you provide references
or otherwise attribute this information (please specify if your organisation requires that this
information is attributed to your organisation instead of yourself). The final advice by the
Committee will be published on the department’s website following the listing decision by the
Minister.
Information provided through consultation may be subject to freedom of information legislation
and court processes. It is also important to note that under the EPBC Act, the deliberations and
recommendations of the Committee are confidential until the Minister has made a final decision
on the nomination, unless otherwise determined by the Minister.
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Notoryctes caurinus
Kakarratul
Taxonomy
Conventionally accepted as Notoryctes caurinus (Thomas, 1920).
Marsupial moles comprise their own marsupial order, the Notoryctemorphia, which may have
branched off from other lineages as much as 64 million years ago (Kirsch et al., 1997). For
some time it was thought that there was a single species of marsupial mole. Two species of
Notoryctes are now recognised (possibly with two ‘forms’ of the Itjaritjari) but recent
morphological and genetic research is yet to be published.
Species Information
Description
The Kakarratul is blind and shows the typical characteristics of other highly fossorial (adapted to
living underground) mammals, including a tubular body shape, an absence of ear pinnae
(external visible part of the ear), heavily keratinised skin on the snout, a reduced tail and dense
fur. In common with most burrowing marsupials, the pouch opens posteriorly as a protection
against the entry of soil (Benshemesh, 2004).
The Kakarratul’s body is covered with dense, silky, golden-brown to pale cream fur which is
often coloured by oxides in the soil. The fur also covers the ear openings. The short and
powerful front limbs have large, spade-like claws on the third and fourth digits of the forepaw.
The species has a head and body length of 86-93 mm and a tail length of 16-18 mm. It is similar
to, but slightly smaller than, the related Itjaritjari (Notoryctes typhlops) and has a relatively
narrower and shorter snout (Benshemesh & Johnson, 2003; Cronin, 1991; Benshemesh & Aplin,
2008).
Distribution
The Kakarratul occurs in the Great Sandy, Little Sandy and the northern Gibson Deserts of
Western Australia, and probably in the western Tanami Desert of Western Australia and western
Northern Territory. Its distribution follows that of the sand dune habitat it prefers. Connectivity of
dunes appears important in determining the distribution, i.e. mole signs are less common where
there is low dune connectivity, and isolated areas of dunes may not be inhabited. The Kakarratul
may be sympatric with the Itjaritjari (N. typhlops) in the eastern and southern parts of its range.
Relevant Biology/Ecology
Kakarratul inhabit sand dunes and, to a lesser extent, adjacent swales where there is suitable
deep, loose sand. Trenching surveys have shown that potential habitat appears to be simply
described as aeolian dunes. They spend almost their entire life underground, only very
occasionally coming to the surface, and only remaining on the surface for a short time. Most
specimens and sightings come from animals found on the surface. However, it appears they
rarely come to the surface, which makes them less prone to predation.
When underground, marsupial moles virtually swim through the soil. The sand is packed in
behind the animal as it progresses and no empty tunnel is formed. Nevertheless, where one has
passed through a soil profile, an oval shaped differentiation in soil texture and colour can be
seen (Johnson and Walton, 1989). Evidence of 80 kilometres of backfilled tunnel per hectare is
averaged in areas where Kakarratul occur (Benshemesh and Mann, 2009; Benshemesh and
Schulz, 2009), representing up to 1% of the soil within one metre of the surface.
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Kakarratul, like Itjaritjari, are insectivorous and capture their prey while underground (Pavey et
al., 2012). There have been no analyses of gut contents but the diet is probably similar to the
Itjaritjari’s, comprising mainly insects, particularly ants and some beetle larvae.
Marsupial moles may be common prey items of larger mammalian predators, especially the
introduced red fox (Vulpes vulpes). In the known range of Kakarratul, Benshemesh et al. (2010)
found remains of marsupial moles in 8% of predator scats, especially foxes, although
differences in incidence in scats between foxes and dingos (and cats) were not significant. Signs
of marsupial moles were found in approximately 5% of predator scats collected from 2008 to
2012 in the Martu native title determination in Western Australia (A. McGilvray pers. comm.,
cited in Woinarski et al., 2014).It is uncertain whether these predators take marsupial moles on
the surface or dig them up, or indeed whether they are actually killing moles or taking dead
animals. Dead or severely debilitated moles have been recorded on the surface on several
occasions (Benshemesh, 2004), but it seems most likely that these predators prey upon living
moles that are on or just under the surface. R. T. Maurice, who travelled widely in the Great
Victoria Desert between 1897 and 1903, reported that local Aboriginal people were able to
capture Itjaritjari after hearing them when they were under the surface (Gara, 1996, cited in
Benshemesh, 2004), and larger mammalian predators may do likewise. Benshemesh et al.
(2010) found some evidence that dingoes (Canis lupus dingo), at least, hunted Kakarratul in
northern areas where it was common to find the remains of more than one marsupial mole in
each dingo scat. On the surface, marsupial moles are vulnerable to a wide range of predators
including birds of prey, snakes and goannas.
Almost nothing is known of reproduction or longevity in marsupial moles (Benshemesh &
Johnson, 2003). Single and twin pouch young have been recorded but pouch young appear very
rarely in museum collections. No marsupial moles have survived in captivity for more than a few
months. Generation time cannot be estimated.
Threats
Threats to the Kakarratul are outlined in the table below (Woinarski et al., 2014).
Threat factor
Predation by red
foxes
Predation by feral
cats
Consequen
ce rating
minor
Extent over which
threat may operate
entire
minor
entire
Evidence base
high proportion (c. 8%) of
introduced predator scats
in the Great Sandy and
Little Sandy Deserts
contained marsupial mole
remains (Benshemesh et
al., 2010)
high proportion (c. 8%) of
introduced predator scats
in the Great Sandy and
Little Sandy Deserts
contained marsupial-mole
remains (Benshemesh et
al., 2010)
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Predation by
dingoes and wild
dogs
minor
entire
Inappropriate fire
regimes
unknown
entire
Flooding
unknown
minor
Noise pollution
unknown
minor (near
developments especially
mines, roads and
railways)
high proportion of dingo
scats in north-west
Western Australia
contained marsupial-mole
remains with some scats
containing several
individuals (Benshemesh
et al., 2010); however no
evidence to indicate that
this pressure may have
increased since European
settlement
large, hot fires may reduce
food availability; however,
trenching surveys suggest
that fire is not a limiting
factor
prolonged periods of rain
and flooding, saturating the
soil profile, may lead to
increased mortality rates
intense or frequent
underground sounds may
damage animals or
interfere with foraging
and/or reproduction
Assessment of available information in relation to the EPBC Act Criteria and Regulations
Criterion 1. Population size reduction (reduction in total numbers)
Population reduction (measured over the longer of 10 years or 3 generations) based on any of A1 to
A4
Critically Endangered
Very severe reduction
Endangered
Severe reduction
Vulnerable
Substantial reduction
A1
≥ 90%
≥ 70%
≥ 50%
A2, A3, A4
≥ 80%
≥ 50%
≥ 30%
A1
A2
Population reduction observed, estimated, inferred or
suspected in the past and the causes of the reduction
are clearly reversible AND understood AND ceased.
Population reduction observed, estimated, inferred
or suspected in the past where the causes of the
reduction may not have ceased OR may not be
understood OR may not be reversible.
A3
Population reduction, projected or suspected to be
met in the future (up to a maximum of 100 years) [(a)
cannot be used for A3]
A4
An observed, estimated, inferred, projected or
suspected population reduction where the time period
must include both the past and the future (up to a
max. of 100 years in future), and where the causes of
reduction may not have ceased OR may not be
understood OR may not be reversible.
(a)
direct observation [except A3]
(b)
an index of abundance appropriate to
the taxon
based
(c)
on any
of the
following
:
(d)
a decline in area of occupancy,
extent of occurrence and/or quality of
habitat
(e)
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actual or potential levels of
exploitation
the effects of introduced taxa,
hybridization, pathogens, pollutants,
competitors or parasites
Evidence:
Maxwell et al. (1996) assessed this species to Endangered A1c,2c using a precautionary
approach because it lies within the ‘critical weight range’ (Burbidge and McKenzie ,1989) (90%
of arid zone species within this weight range have become extinct or declined significantly), and
because of the apparent high predation rate by introduced red foxes. At that time, it was
impossible to know whether the low rate of sightings and specimen acquisition was due to
increasing rarity or to a relatively common species that is infrequently observed because of its
fossorial behaviour.
Recent surveys show that Kararratul are widespread and common throughout much of their
known range, and there is no evidence of an ongoing decline (Woinarski et al, 2014).
The data presented above appear to demonstrate the species is not eligible for listing under this
criterion. However, the purpose of this consultation document is to elicit additional information to
better understand the species’ status. This conclusion should therefore be considered to be
tentative at this stage, as it may be changed as a result of responses to this consultation
process.
Criterion 2. Geographic distribution is precarious for either extent of occurrence
AND/OR area of occupancy
Critically Endangered
Very restricted
Endangered
Restricted
Vulnerable
Limited
B1. Extent of occurrence (EOO)
< 100 km2
< 5,000 km2
< 20,000 km2
B2. Area of occupancy (AOO)
< 10 km2
< 500 km2
< 2,000 km2
=1
≤5
≤ 10
AND at least 2 of the following 3 conditions:
(a)
Severely fragmented OR Number of
locations
(b)
Continuing decline observed, estimated, inferred or projected in any of: (i) extent of occurrence; (ii) area of
occupancy; (iii) area, extent and/or quality of habitat; (iv) number of locations or subpopulations; (v) number of
mature individuals
(c)
Extreme fluctuations in any of: (i) extent of occurrence; (ii) area of occupancy; (iii) number of locations or
subpopulations;( iv) number of mature individuals
Evidence:
The extent of occurrence is estimated to be 290 000 km2; however, this is likely to be an
underestimate due to the lack of survey and misidentification of the two species of marsupial
moles. Evidence of the Kakarratul has been found in most areas of suitable habitat (dunes)
within the distribution. The area of occupancy is unknown but is likely to be > 2000 km2
(Woinarski et al., 2014).
The data presented above appear to demonstrate that the species is not eligible for listing under
this criterion. However, the purpose of this consultation document is to elicit additional
information to better understand the species’ status. This conclusion should therefore be
considered to be tentative at this stage, as it may be changed as a result of responses to this
consultation process.
Criterion 3.
Small population size and decline
Estimated number of mature individuals
Critically
Endangered
Very low
Endangered
Low
Vulnerable
Limited
< 250
< 2,500
< 10,000
AND either (C1) or (C2) is true
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C1
An observed, estimated or projected
continuing decline of at least (up to a
max. of 100 years in future)
C2
An observed, estimated, projected or
inferred continuing decline AND its
geographic distribution is precarious
for its survival based on at least 1 of
the following 3 conditions:
(a)
(b)
Very high rate
25% in 3 years or 1
generation
(whichever is longer)
High rate
20% in 5 years or 2
generations
(whichever is
longer)
Substantial rate
10% in 10 years or 3
generations
(whichever is longer)
≤ 50
≤ 250
≤ 1,000
90 – 100%
95 – 100%
100%
(i) Number of mature individuals in
each subpopulation
(ii) % of mature individuals in one
subpopulation =
Extreme fluctuations in the number of
mature individuals
Abundance is unknown, but evidence of the species has been found in most areas of suitable
habitat (dunes) within the distribution. Woinarski et al. (2014) consider that the population size is
likely to be > 10 000 mature individuals.
There are insufficient data to demonstrate if the species is eligible for listing under this criterion.
However, the purpose of this consultation document is to elicit additional information to better
understand the species’ status. This conclusion should therefore be considered to be tentative
at this stage, as it may be changed as a result of responses to this consultation process.
Criterion 4.
Very small population
Critically Endangered
Extremely low
Endangered
Very Low
Vulnerable
Low
< 50
< 250
< 1,000
Number of mature individuals
Evidence:
Woinarski et al. (2014) consider that the population size is likely to be > 10 000 mature
individuals.
The data presented above appear to demonstrate that the species is not eligible for listing under
this criterion. However, the purpose of this consultation document is to elicit additional
information to better understand the species’ status. This conclusion should therefore be
considered to be tentative at this stage, as it may be changed as a result of responses to this
consultation process.
Criterion 5.
Quantitative Analysis
Indicating the probability of extinction in
the wild to be:
Critically Endangered
Immediate future
Endangered
Near future
Vulnerable
Medium-term future
≥ 50% in 10 years or 3
generations,
whichever is longer
(100 years max.)
≥ 20% in 20 years or
5 generations,
whichever is longer
(100 years max.)
≥ 10% in 100 years
Evidence:
No population viability analysis has been undertaken.
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There are insufficient data to demonstrate if the species is eligible for listing under this criterion.
However, the purpose of this consultation document is to elicit additional information to better
understand the species’ status. This conclusion should therefore be considered to be tentative
at this stage, as it may be changed as a result of responses to this consultation process.
Consideration for delisting
There is no species-specific management in place, but some fire management is occurring in a
few areas (Woinarski et al., 2014). A recovery plan for marsupial moles has been developed by
the Northern Territory Government (Benshemesh, 2004). Delisting the species is not expected
to result in the loss of any recovery actions that could result in it becoming eligible for re-listing in
the future.
Conservation Actions
Recovery Plan
A decision about whether there should be a recovery plan for this species has not yet been
determined. The purpose of this consultation document is to elicit additional information to help
inform this decision.
A recovery plan for marsupial moles has been prepared by the Northern Territory Department of
Infrastructure, Planning and Environment (Benshemesh, 2004). The recovery actions included in
the recovery plan are as follows:
 Assess distribution of marsupial moles
 Monitor population trends
 Resolve taxonomy
 Assess the threats imposed by fire, grazing and predation, particularly by introduced
foxes and cats
 Obtain ecological information from Aboriginal elders
 Refine knowledge of diet and determine sex, reproductive state and general condition
from museum specimens
 Prepare for captive individuals
 Co-ordinate and manage the recovery process through a recovery team
 Downlist from endangered to lower category.
Implementation of the plan is well progressed. Information on distribution has been obtained via
surveys and mapping, and a monitoring and survey manual has been produced although no
ongoing monitoring programs are currently in place. Taxonomic work has been undertaken but
is unpublished. In Western Australia traditional ecological knowledge of the Kakarratul is being
collected where possible through partnerships with Indigenous groups and landholders
(Woinarski et al., 2014).
Primary Conservation Objectives
1. Seek to more definitively assess status and management requirements
2. Maintain viable populations across known range
Conservation and Management Actions
Recommended management actions are outlined in the table below (Woinarski et al., 2014).
Theme
Active mitigation of threats
Specific actions
reduce the incidence of largescale, intense fires and promote
a mosaic of areas with differing
times since fire
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Priority
medium
Captive breeding
Quarantining isolated populations
Translocation
Monitoring
Community engagement
eradicate or effectively control
foxes and feral cats at selected
sites
n/a
n/a
n/a
monitor marsupial mole numbers
at selected sites
involve Aboriginal communities
in Kakarratul research and
monitoring
low
medium
medium
Information and research priorities
Information and research priorities are outlined in the table below (Woinarski et al., 2014).
Theme
Survey to better define distribution
Assess impacts of threats on species
Establish or enhance monitoring
program
Assess effectiveness of threat mitigation
options
Resolve taxonomic uncertainties
Assess habitat requirements
Assess diet, life history
Specific actions
continue to develop costeffective and reliable sampling
methodology
map distribution of marsupial
moles, estimate population size
and identify important
subpopulations
establish the relationship
between density of back-filled
tunnels and Kakarratul
population density (requires
knowledge of tunnelling
rates/individual and longevity of
signs of tunnels)
develop methods for live capture,
thus allowing tracking
assess population-level impact of
predation by feral cats
assess population-level impact of
predation by red foxes
assess responses to a range of
fire regimes
monitor Kakarratul relative
abundance at selected sites
assess relative abundance of
marsupial moles at sites where
feral cats and foxes are
eradicated or effectively
controlled
complete and publish
morphological and genetics
research
assess population density across
a range of different habitat types
collect diet and life history data,
especially age at first
reproduction and longevity
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Priority
medium
medium
medium
low
low
low
low
medium
low
medium
medium
medium
References cited in the advice
Benshemesh, J. (2004). Recovery Plan for Marsupial Moles Notoryctes typhlops and N.
caurinus. 2005-2010. Northern Territory Department of Infrastructure, Planning and
Environment: Alice Springs. Available on the Internet at:
http://www.environment.gov.au/biodiversity/threatened/publications/marsupialmoles.html
Benshemesh, J, and Aplin, K.P. (2008). Kakarratul Notoryctes caurinus. In ‘The mammals of
Australia’. Third edition. (Eds S. Van Dyck and R. Strahan.) pp. 410-411. Reed New
Holland: Sydney.
Benshemesh, J., and Johnson, K. A. (2003). Biology and conservation of marsupial moles
(Notoryctes). In ‘Predators with Pouches. The Biology of Carnivorous Marsupials’. (Eds
M. Jones, C. Dickman and M. Archer.) pp. 464- 474. (CSIRO Publishing: Collingwood.)
Benshemesh, J., and Mann, S. (2009). Survey of marsupial moles in North central WA: Great
Sandy, Gibson and Little Sandy Deserts. Report to Department of Natural Resources,
Environment and the Arts, Northern Territory Government.
Benshemesh, J., Schulz, M. (2009). Survey of marsupial moles in North west WA and NT:
Tanami Desert, Great Sandy Desert and Dampierland Bioregions. Report to Department
of Natural Resources, Environment and the Arts, Northern Territory Government
Benshemesh, J., Paltridge, R., and Schulz, M. (2010). Marsupial mole remains in predator
scats. Report to Department of Natural Resources, Environment and the Arts, Northern
Territory Government, Alice Springs.
Burbidge, A. A., and McKenzie, N. L. (1989). Patterns in the modern decline of Western
Australia's vertebrate fauna: causes and conservation implications. Biological
Conservation 50, 143-198.
Cronin, L. (1991). Key Guide to Australian Mammals. Balgowlah, NSW: Reed Books.
Johnson, K. A., and Walton, D. W. (1989). Notoryctidae. In ‘Fauna of Australia: Volume 1B
Mammalia.’ (Eds D. W. Walton and B. J. Richardson.) pp 591-602. (Australian
Government Publishing Service: Canberra.)
Kirsch, J. A. W., Lapointe, F.-J., and Springer, M. S. (1997). DNA-hybridisation studies of
marsupials and their implications for metatherian classification. Australian Journal of
Zoology 45:211-280.
Maxwell, S., Burbidge, A. A., and Morris, K. (1996). ‘The 1996 action plan for Australian
marsupials and monotremes.’ (Wildlife Australia: Canberra.)
Pavey, C. R., Burwell, C. J., and Benshemesh, J. (2012). Diet and prey selection of the southern
marsupial mole: an enigma from Australia's sand deserts. Journal of Zoology 287, 115123.
Withers, P. C., Thompson, G. G., and Seymour R. S. (2000). Metabolic physiology of the northwestern marsupial mole, Notoryctes caurinus (Marsupialia: Notoryctidae). Australian
Journal of Zoology 48, 241-258.
Woinarski, J. C. Z., Burbidge, A. A., & Harrison, P. L. (2014). The Action Plan for Australian
Mammals 2012. Collingwood, Australia: CSIRO Publishing.
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Consultation questions
1. Do you agree with the current taxonomic position of the Australian Faunal Directory for this
taxon (as identified in the draft conservation advice)
2. Can you provide any additional references, information or estimates on longevity, age of
maturity, average life span and generation length?
3. Has the survey effort for this taxon been adequate to determine its national distribution and
adult population size?
4. Do you accept the estimate provided in the nomination for the current population size of the
taxon?
5. For any population with which you are familiar, do you agree with the population estimate
provided? If not, are you able to provide a plausible estimate based on your own
knowledge? If so, please provide in the form:
Lower bound (estimated minimum):
Upper bound (estimated maximum):
Best Estimate:
Estimated level of Confidence: %
6. Can you provide any additional data, not contained in the current nomination, on declines in
population numbers over the past or next 10 years or 3 generations, whichever is the
longer?
7. Is the distribution as described in the nomination valid? Can you provide an estimate of the
current geographic distribution (extent of occurrence or area of occupancy in km2) of this
taxon?
8. Has this geographic distribution declined and if so by how much and over what period of
time?
9. Do you agree that the taxon is eligible for inclusion on the threatened species list, in the
category listed in the nomination?
10. Do you agree that the threats listed are correct and that their effects on the taxon are
significant?
11. To what degree are the identified threats likely to impact on the taxon in the future?
12. Can you provide additional or alternative information on threats, past, current or potential
that may adversely affect this taxon at any stage of its life cycle?
13. In seeking to facilitate the recovery of this taxon, can you provide management advice for
the following:
 What individuals or organisations are currently, or need to be, involved in planning to
abate threats and any other relevant planning issues?
 What threats are impacting on different populations, how variable are the threats and
what is the relative importance of the different populations?
 What recovery actions are currently in place, and can you suggest other actions that
would help recover the taxon? Please provide evidence and background information.
14. Can you provide additional data or information relevant to this assessment?
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